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Swedish Forest Industries Federation

SFIF

The Swedish Forest Industries Federation represents pulp, paper, and woodworking companies in Sweden.

Lobbying Activity

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

12 Dec 2025 · EU:n biotalousstrategia

Meeting with Elsi Katainen (Member of the European Parliament)

12 Dec 2025 · Bioeconomy strategy event

Meeting with Alexandre Paquot (Director Climate Action) and

11 Dec 2025 · Contribution of the land use sector and forestry to the EU climate targets

Meeting with Alice Teodorescu Måwe (Member of the European Parliament)

11 Dec 2025 · Skogspolitik

Meeting with Pär Holmgren (Member of the European Parliament)

11 Dec 2025 · Forest policy

Meeting with Stefan Köhler (Member of the European Parliament)

18 Nov 2025 · Politischer Austausch zu forstpolitischen Themen und EUDR

Meeting with Stella Kaltsouni (Cabinet of Commissioner Dan Jørgensen) and Confederation of European Paper Industries and

6 Nov 2025 · Decarbonisation and maintaining global competitiveness

Meeting with Peter Liese (Member of the European Parliament)

15 Oct 2025 · Austausch

Meeting with Pär Holmgren (Member of the European Parliament)

2 Oct 2025 · Vattenresiliens

Swedish Forest Industries urges nature credits to support wood supply

30 Sept 2025
Topic — EU roadmap for creating a voluntary nature credit framework for biodiversity enhancement.
Message — The federation requests balanced stakeholder representation including forest actors, flexibility in implementation methods focused on outcomes rather than prescriptive practices, and voluntary participation without legislative mandates. They emphasize nature credits must maintain sustainable wood supply for the bioeconomy.123
Why — This would protect their wood supply and competitiveness while accessing new revenue from nature credits.45
Impact — Climate mitigation loses as biodiversity-focused forestry reduces carbon sequestration and fossil replacement materials.67
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Meeting with Antti Timonen (Cabinet of Executive Vice-President Henna Virkkunen)

30 Sept 2025 · Exchange of views on the importance of forestry in Europe

Meeting with Kirsi Haavisto (Head of Unit Research and Innovation)

30 Sept 2025 · FP10 - RTI Strategy

Meeting with Heléne Fritzon (Member of the European Parliament)

25 Sept 2025 · skogsfrågor, övergripande

Swedish Forest Industries urges longer timelines for bio-CCS certification

22 Sept 2025
Topic — EU methodologies for certifying permanent carbon removal activities including biochar and bio-CCS.
Message — The organization requests extending activity periods to at least 20 years and eliminating compensation requirements. They argue short timelines prevent large industrial investments and that LCA methodology creates problematic double counting with ETS.123
Why — Longer timelines would enable major industrial investments with decades-long technical and economic lifespans.45
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Meeting with Ilaria Flores Martin (Cabinet of Commissioner Jessika Roswall), Jan Ceyssens (Cabinet of Commissioner Jessika Roswall)

16 Sept 2025 · Forest-based bioeconomy

Swedish Forest Industries urges fossil substitution priority in 2040 climate target

10 Sept 2025
Topic — EU regulation setting 2040 climate target to achieve climate neutrality by 2050.
Message — The organization requests that substitution of fossil-based materials be prioritized and measured in climate legislation. They want substitution targets for sectors and products, and changes to LULUCF rules to avoid hindering bioeconomy potential. They ask for indicative rather than binding carbon sink targets.12345
Why — This would create demand for their bio-based products and maintain access to forest raw materials.67
Impact — Environmental groups lose stronger short-term protections for forest carbon sinks and afforestation controls.89
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Meeting with Christian Holzleitner (Head of Unit Climate Action)

14 Jul 2025 · Trends in LULUCF development Business opportunities with CRCF

Swedish Forest Industries urges removal of 95% biofuel rule in EU ETS

7 Jul 2025
Topic — Review of EU Emissions Trading System carbon leakage protections and biogenic carbon treatment.
Message — The federation demands abolition of the 95%-rule that excludes installations using predominantly biofuels from ETS carbon leakage protection. They want all installations producing carbon leakage list products included in ETS regardless of fuel type, with centrally-funded indirect cost compensation and clear differentiation between fossil and biogenic carbon dioxide in support systems.1234
Why — This would restore carbon leakage protection for 25 Swedish installations representing 75% of production.56
Impact — Fossil fuel-dependent competitors lose advantage over facilities that invested in biofuel transition.7
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Meeting with Alexander Bernhuber (Member of the European Parliament)

19 Jun 2025 · Entwaldungsverordnung

Meeting with Alice Teodorescu Måwe (Member of the European Parliament)

13 Jun 2025 · Forestry

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

11 Jun 2025 · Biotalouden kasvu

Meeting with Raffaele Fitto (Executive Vice-President) and Stora Enso Oyj and

22 May 2025 · Round table discussion concerning bio economy and its implications on regional policy

Meeting with Heiko Kunst (Head of Unit Climate Action)

21 May 2025 · Share views on the 95% rule for biomass users in the EU ETS

Meeting with Karin Karlsbro (Member of the European Parliament) and Billerud AB

21 May 2025 · EU:s klimatlagstiftning

Meeting with Jörgen Warborn (Member of the European Parliament)

21 May 2025 · SMEs

Meeting with Jessika Roswall (Commissioner) and

20 May 2025 · Forest issues

Meeting with Heléne Fritzon (Member of the European Parliament)

20 May 2025 · Lunch med svensk och finsk skogsindustri maa 30 år i EU

Meeting with Hans Ingels (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

20 May 2025 · Bioeconomy

Meeting with Emma Wiesner (Member of the European Parliament, Rapporteur) and Finnish Forest Industries Federation (Metsäteollisuus ry)

20 May 2025 · EUs klimat och skogspolitik

Meeting with Christophe Hansen (Commissioner) and

20 May 2025 · Forestry, EU bioeconomy strategy, improvement of the EU competitiveness while reaching the climate goals, and how the industry best can contribute to this work

Meeting with Emmanuelle Maire (Head of Unit Environment)

6 May 2025 · Bioeconomy Strategy

Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen) and Billerud AB

29 Apr 2025 · The upcoming bioeconomy strategy and the so-called substitution effect in relation to it

Meeting with Emma Wiesner (Member of the European Parliament) and Billerud AB

29 Apr 2025 · EUs handel med utsläppsrätter

Meeting with Aurel Ciobanu-Dordea (Director Environment)

28 Apr 2025 · Discussion on the use of wood-based materials, short-lived vs. long-lived products, and the role of carbon capture and storage (CCS).

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra)

19 Mar 2025 · The role of forests in climate objectives

Meeting with Antonina Cipollone (Head of Unit Secretariat-General), Vesa Terävä (Head of Unit Secretariat-General)

18 Mar 2025 · EU Deforestation Regulation (EUDR)

Meeting with Alice Teodorescu Måwe (Member of the European Parliament) and Confederation of Swedish Enterprise and Byggföretagen

7 Mar 2025 · Vatten

Response to European Water Resilience Strategy

4 Mar 2025

The Swedish Forest Industry see the importance of a water resilience strategy. Water is essential for all life and the risks of water shortages or excesses are increasing. However, Europe is a very large area with considerable differences in water availability. A European strategy needs to respect these differences and create a framework that strengthens Europe's resilience and competitiveness rather than creating obstacles to sustainable development. For the forest industry, water is an essential resource. In the attached file are comments that we have put together in a broad Swedish composition.
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Meeting with Alice Teodorescu Måwe (Member of the European Parliament)

19 Feb 2025 · Skogsfrågor

Meeting with Jessica Polfjärd (Member of the European Parliament)

19 Feb 2025 · Forestry policy

Meeting with Elsi Katainen (Member of the European Parliament, Shadow rapporteur)

18 Feb 2025 · Forest issues

Meeting with Johan Danielsson (Member of the European Parliament, Shadow rapporteur) and ASTOC – Association of Swedish Train Operating Companies and SJ AB

28 Jan 2025 · Capacity Regulation

Meeting with Eero Heinäluoma (Member of the European Parliament)

14 Jan 2025 · New Year Reception

Meeting with Emma Wiesner (Member of the European Parliament)

14 Jan 2025 · Skogen och EUs klimatneutralitet

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

13 Jan 2025 · EUDR implementation and Circular Economy

Meeting with Axel Hellman (Cabinet of Commissioner Jessika Roswall), Paulina Dejmek Hack (Cabinet of Commissioner Jessika Roswall)

3 Dec 2024 · To discuss policy initiatives of the new Commission.

Meeting with Pär Holmgren (Member of the European Parliament) and Confederation of Swedish Enterprise

27 Nov 2024 · Climate and Environmental policies

Meeting with Kurt Vandenberghe (Director-General Climate Action)

25 Nov 2024 · General exchange of views regarding the upcoming Commission initiatives in the field of EU climate policy in the new mandate and how the industry can contribute to achieving the 2040 targets

Meeting with Karin Karlsbro (Member of the European Parliament) and Confederation of Swedish Enterprise

22 Nov 2024 · Aktuella frågor inom miljöutskottet

Meeting with Alexander Bernhuber (Member of the European Parliament, Shadow rapporteur)

19 Nov 2024 · EU Waldmonitoringrahmen

Meeting with Katri Kulmuni (Member of the European Parliament)

14 Nov 2024 · a Water Resilience Europe and the Water Framework Directive

Meeting with Alice Teodorescu Måwe (Member of the European Parliament)

26 Sept 2024 · Skogsfrågor under mandatperioden

Meeting with Emma Wiesner (Member of the European Parliament)

9 Sept 2024 · Lunch för att prata om den nya mandatperioden och prioriteringar

Meeting with Eero Heinäluoma (Member of the European Parliament)

5 Sept 2024 · Current Affairs

Meeting with Sofie Eriksson (Member of the European Parliament)

26 Jun 2024 · Skogspolitik inför den kommande mandatperioden

Response to Report on the evaluation of the LULUCF Regulation

25 Jun 2024

LULUCF policies should be based on balanced and realistic assessments of the forests natural dynamics and consider other sustainability dimensions Maintaining natural carbon sinks in the long term is a crucial part of reaching climate goals, also beyond 2050. This should, however, not be compromised by focusing on short term targets or unreasonable burdens on specific Member States. Fossil emissions or a declining carbon sink in one Member State cannot simply be compensated by carbon sink in another Member State. Sweden has a large carbon sink from maintaining and restoring large forest areas over time with active and sustainable forest management. The potential to maintain the sink is connected to the possibility of continued active management. Ensuring and increasing forest growth is a determining factor for sustaining a long-term carbon sink. Policies for natural carbon sinks must consider the natural variations year to year but also larger trends like the age structure and health of the forest and the long-term development of the forest carbon sink. For example, more restrictions on forest management could lead to a higher average forest age, resulting in lower growth and carbon sink as well as increased risks of forest damages from storms, fires, and pests. An international research report that analyzes data reported to the UNFCCC by the countries in the northern coniferous forest belt during the years 19902017 shows that greater climate benefit is achieved in actively managed boreal forests compared to unmanaged forests. The managed forest sequesters more carbon than the unmanaged forest and the carbon stock in the managed boreal forest landscapes is increasing, while it is relatively unchanged in less intensively utilized forests, where the carbon losses due to forest fires have been significant. Most importantly the potential carbon sink in each Member State should be estimated by forest experts and forest managers with a bottom-up approach. This should include the specific forest dynamics in the Member State as well as basic parameters such as site productivity and forest management. The policies need to be balanced in relation to the dynamics of forests as well as other climate and sustainability aspects of the forest-based bioeconomy, including forest-based products and technical carbon sinks, and take a long-term view. Products and energy from forests are just as central to climate change mitigation as large and growing forests that absorb and store carbon. The way LULUCF is designed leads to a prioritisation of carbon storage in forests over the production of renewable raw materials for products and bioenergy. This means less climate benefit already in the short term as less renewable and sustainable raw materials would be available to make products that we need in our every-day lives helping us use fewer products made of oil and coal. A report on the contribution of the EU forest-based sector estimates the overall climate change mitigation effect to 806 million tonnes of CO2e annually. This corresponds to 20 percent of all fossil emissions in the European Union. Roughly half of this mitigation benefit comes from the displacement of fossil-based emissions. An effective and long-term sustainable LULUCF climate policy should focus on sustainably increased growth in the forest combined with targets for increased substitution of fossil materials. Measuring and annually reporting the substitution effect from the forest-based value-chain would shed light on the forest's entire climate benefit. Enlarging the scope of the Harvested Wood Products categories is a step in the right direction. Developing stronger policies for Bioenergy Carbon Capture and Storage (BECCS) would be another.
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Meeting with Florika Fink-Hooijer (Director-General Environment)

12 Jun 2024 · Implementation of the EU Deforestation Regulation in SE value chain

Response to Update of related legislation as a consequence of the new regulation on recycled plastic Food Contact Materials

12 Apr 2024

Skogsindustrierna tackar för möjligheten att lämna synpunkter på detta samråd kring förslaget Säkra livsmedel plast i kontakt med livsmedel (uppdaterade regler för kvalitetskontroll). Skogsindustrierna har valt att besvara detta samråd med anledning av att det koncept/metodik som föreslås skulle riskeras att appliceras på den kommande harmoniserade FCM-lagstiftningen. Skogsindustrierna efterfrågar att de materialspecifika FCM-lagstiftningar som revideras, ska utformas så att de är relevanta och tillämpbara i praktiken och på så sätt skulle kunna vara en del av den kommande harmoniserade FCM-lagstiftning.
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Meeting with Nils Torvalds (Member of the European Parliament)

21 Mar 2024 · The state of EU politics

Swedish forest industry seeks realistic BPA monitoring and thresholds

7 Mar 2024
Topic — Proposed EU regulation banning intentionally added Bisphenol A in food contact materials.
Message — SFIF requests flexible monitoring frequencies and clear calculation methods for continuous paper production. They urge for a harmonized BPA threshold aligned with existing standards for recycled fiber. The federation recommends exempting recyclers from follow-up investigations for non-intentional contamination.123
Why — These changes would minimize administrative costs and prevent arbitrary sampling requirements for recyclers.4
Impact — Consumers might face higher trace levels of BPA due to more lenient detection thresholds.5
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Meeting with Tomas Tobé (Member of the European Parliament) and The Wallenberg Investments AB

21 Feb 2024 · Industry Policy

Meeting with Tomas Tobé (Member of the European Parliament) and Confederation of Swedish Enterprise

16 Feb 2024 · Industry policy

Meeting with Elsi Katainen (Member of the European Parliament, Shadow rapporteur)

15 Jan 2024 · Weights and dimensions directive

Meeting with Peter Liese (Member of the European Parliament)

6 Dec 2023 · Austausch

Meeting with Nils Torvalds (Member of the European Parliament)

5 Dec 2023 · Forest Monitoring Framework

Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur) and CONSEIL EUROPEEN DES JEUNES AGRICULTEURS

16 Nov 2023 · Soil Health Law

Swedish Forest Industries demand national flexibility in soil law

2 Nov 2023
Topic — New EU legislation defining conditions for healthy soil monitoring and sustainable restoration.
Message — The federation calls for respecting subsidiarity and limiting the Commission's secondary legislative powers. They request a rational monitoring framework reflecting the slow changes in forest soils. Sustainable management principles should remain exemplary to allow for national variations.123
Why — This ensures stable wood raw material supplies and minimizes costly reporting requirements.45
Impact — Environmental transparency decreases if geospatial soil health data is withheld from public view.6
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Meeting with Alice Brokelind (Cabinet of Commissioner Ylva Johansson)

19 Sept 2023 · Forestry, Green Deal and the new EU Framework for Forest Monitoring and Strategic Plans

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur) and Confederation of Swedish Enterprise and Svensk Handel

18 Sept 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Swedish forest industry urges clarity on green claim rules

14 Jul 2023
Topic — The EU is proposing rules to substantiate environmental product claims.
Message — SFIF calls for a mechanism allowing commercial stakeholders to contribute to monitoring and implementation. They urge the Commission to clarify vague criteria to prevent the risk for arbitrary interpretation. They also demand industry involvement during the development of secondary legislation.123
Why — Specific guidelines would reduce the risk of facing unpredictable legal consequences.4
Impact — Environmental groups lose influence if product rules are shaped by industry majorities.5
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Meeting with Alice Brokelind (Cabinet of Commissioner Ylva Johansson), Asa Webber (Cabinet of Commissioner Ylva Johansson)

4 Jul 2023 · Green Deal files and environmental protection

Meeting with Nils Torvalds (Member of the European Parliament, Shadow rapporteur for opinion)

6 Jun 2023 · Packaging and packagingwaste, nature restoration law

Meeting with Ville Niinistö (Member of the European Parliament, Shadow rapporteur)

6 Jun 2023 · Carbon removals

Meeting with Florika Fink-Hooijer (Director-General Environment)

24 May 2023 · Exchange of opinions on the upcoming proposal for Forest Monitoring & Strategic Plans and the forest-based circular bioeconomy in EU policy

Meeting with Henna Virkkunen (Member of the European Parliament)

10 May 2023 · EU Packaging and Packaging Waste Regulation (PPWR)

Swedish Forest Industries Federation seeks flexibility in circularity rules

3 May 2023
Topic — The consultation establishes technical criteria for economic activities contributing to EU environmental objectives.
Message — The organization urges that mandatory recycled content initially apply to predominantly plastic packaging. They argue that targets should be modulated based on the percentage of biobased content used. Finally, they request an exemption for cardboard packaging to ensure a level playing field.123
Why — These adjustments would prevent increased production and transport costs for Northern European industries.4
Impact — Plastic packaging producers would lose the competitive advantage granted by current reuse criteria.5
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Meeting with Nils Torvalds (Member of the European Parliament, Shadow rapporteur for opinion)

20 Mar 2023 · Packaging and packagingwaste

Meeting with Salvatore De Meo (Member of the European Parliament, Rapporteur)

16 Mar 2023 · PPWR

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

1 Feb 2023 · They would like to talk on the ongoing work on the Forest Monitoring legislation

Swedish forest industry urges incentives for renewable packaging materials

30 Jan 2023
Topic — The EU is revising packaging rules to reduce waste and improve design.
Message — SFIF wants incentives for renewable materials and science-based reuse targets. They propose applying recycled content quotas only to packaging primarily made of plastic.12
Why — This would allow wood-based industries to expand by substituting fossil-based packaging.3
Impact — Food distributors and consumers may suffer from increased waste due to bans.4
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Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson), Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

30 Nov 2022 · To discuss on the ongoing work RED, ETS but also more general policies on how to reform the electricity market.

Meeting with Emma Wiesner (Member of the European Parliament)

29 Nov 2022 · Möte om utsläppshandel och förnybartdirektivet

Meeting with Florika Fink-Hooijer (Director-General Environment)

7 Nov 2022 · Deforestation

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

25 Oct 2022 · To discuss the upcoming legislative initiative on carbon removal certification

Meeting with Jakop G. Dalunde (Member of the European Parliament, Shadow rapporteur)

8 Sept 2022 · ESPR (Staff Level)

Meeting with Pär Holmgren (Member of the European Parliament)

7 Sept 2022 · RED & deforestation (staff level)

Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson)

30 Jun 2022 · To discuss the ongoing work on RePowerEU and RED.

Response to Sustainable Products Initiative

2 Jun 2022

Swedish Forest Industries Federation (SFIF) welcomes the European Commission’s ecodesign requirements for sustainable products as well as the establishment of overarching sustainability requirements. In the framework of the European Green Deal and the Circular Economy Action Plan, it is crucial to ensure that products placed on the European market contribute to reach the climate neutrality by 2050 objective. The proposal for setting ecodesign requirements for sustainable products is an ambitious legislation. It contains many good parts, however, SFIF would like to highlight a number of changes to overcome some challenges we foresee in the upcoming delegated acts. 1. Include renewability of raw materials as an additional ecodesign requirement It is important, whenever possible, to incentivise products made from renewable – sustainably managed - resources rather than those made from finite resources. This would facilitate shifting from today’s linear, fossil-based economy to a circular and bio-based one. 2. Include products’ contribution to maintained and increased EU resilience as an ecodesign additional requirement EU needs to increase its resilience. Wood-based materials already support European resilience in several ways. 3. Ecodesign requirements need to be developed based on relevant Union legislation or other instruments Requirements for specific products or product groups need to be specific, coherent and cost-efficient. Furthermore, development of requirements needs to take into consideration relevant technical characteristics for that specific product or group of products. 4. Assure adequate industry representation in the Ecodesign Forum The composition of the Ecodesign Forum needs to cover the full width of relevant value chain, with a majority of stakeholders having knowledge about the actual product or the product group in question. 5. Ensure the use of self-regulation measures to facilitate the implementation of Ecodesign requirements By allowing and applying self-regulation assessment, this will incentivise for more products to be able to fulfil compliance of Ecodesign requirements. 6. Requirement of recycled content needs to be applied smartly Mandatory recycled content can be a useful policy instrument to support and build markets for recycled materials. However, if applied on already existing and well-functioning recycling markets, mandatory recycled content risks being counterproductive and can even jeopardize market functionality.
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Confederation of European Paper Industries and

30 May 2022 · Meeting with Fibre Packaging Europe

Response to New EU Forest Monitoring and Strategic Planning Framework

6 May 2022

The Swedish Forest Industries Federation (SFIF) welcomes the opportunity to provide input on this call for evidence. SFIF fully supports the view that better data and information enables better decision making. It is of crucial importance that the impact assessment clarifies a number of issues. SFIF wishes to highlight the following: 1. Clarify purpose and added value and make use of existing reporting schemes. SFIF welcomes efforts to harmonize and streamline forest reporting. However, first the added value and purpose of a new framework must be clarified, as well as in which areas harmonisation is needed, which data are needed and where possible information gaps lie. This must also be assessed in relation to already existing reporting schemes at various levels. Already today comprehensive data collection on forest resources is undertaken at global, pan-European and EU level, under for example the FAO Forest Resources Assessment, Forest Europe, UNECE and related to various existing EU legislation. A new EU framework must make use of existing reporting schemes, avoiding overlaps in data collection, minimizing reporting burden and ensuring cost-effectiveness. If more or other data is needed, it might be more efficient to further develop/expand existing reporting schemes instead of developing new frameworks. SFIF highlights natural disturbances and disasters, such as forest fires, droughts, and insect outbreaks, as an area where increased EU action would be welcomed, for example by cooperation on early warning and information systems to help monitor significant transboundary impacts of forest disturbances. 2. Build on Member States’ national forest inventory systems. At national level, National Forest Inventories provide official national statistics on forests, often on which international reporting mentioned above is based. The Swedish National Forest Inventory dates from 1923, providing a consistent time-series of high-quality data on the state and changes in Swedish forests. The data is for example used to assess and guide policy options and management practises. Many Member States have similar programmes providing high quality data on their forests. SFIF highlights that Member States should continue to gather official national statistics on forests and that field-based data from these inventories provide the most accurate and reliable data source for forest monitoring. This data should be the basis for the current initiative. Field-based data cannot be replaced by remote sensing, but rather remote sensing can be further developed as a complementary tool, if it is calibrated with field-based measurements. An example of limitations of remote sensing and the need for combining remote sensing with the use of large-scale, field-based data is outlined in Breidenbach et al (2022). A priority in the upcoming legislative framework should be to support Member States in developing capacities related to forest monitoring and reporting, especially related to developing National Forest Inventories to achieve better quality data and facilitate knowledge-sharing and harmonization between Member States. 3. Strategic forest planning should be done at national level. SFIF opposes EU legislation to “plan for transformations in forests and the forest-based sector” at EU level and questions the need for Strategic Forest Plans. We reiterate the Council Conclusions on the new EU Forest Strategy asking for clarifications on the added value of such plans, also in relation to already existing comprehensive national forest programmes or strategies and their related Member States competencies. SFIF highlights that the subsidiarity principle needs to be fully respected and that existing national forest programmes, or equivalent, are sufficient strategic tools for long-term planning for forest and forest-based sectors at the national level. Data, monitoring and planning in relation to forest management should be done by Member States at national level.
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Swedish Forest Industries urge focus on active management and BECCS

2 May 2022
Topic — Commission proposal for a regulatory framework to certify ecosystem and industrial carbon removals.
Message — The federation calls for a framework prioritizing active forest management and wood harvesting. They advocate for financial support for BECCS and inclusion in existing accounting systems. They also argue that additionality is an arbitrary concept for managed forests.123
Why — This would secure their raw material supply while providing subsidies for industrial carbon capture.45
Impact — Environmental groups lose influence as the industry prioritizes wood harvesting over passive forest conservation.6
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

22 Apr 2022 · Circular economy, ecodeisng for sustainable products regulation

Meeting with Frans Timmermans (Executive Vice-President) and Stora Enso Oyj and

31 Mar 2022 · Forest policy and the EU Green Deal roundtable discussion

Response to Evaluation and revision of the Weights and Dimensions Directive

18 Feb 2022

The Swedish Forest Industries Federation (Skogsindustrierna), thanks for the opportunity to participate in this call for evidence. We look forward to the Commission's public consultation on the coming revision on European Directive 96/53/EC later this year. The Swedish Forest Industries Federation is one of the largest industry branches in Sweden. The industry is also one of the largest cargo owners, also called shippers, with 25 million tons of finished goods exported every year, mainly to European destinations but also worldwide. Besides exports, the forest industry also transports raw materials to the mills and factories and account for almost 25 percent of all lorry transport within Sweden. Therefore, the sector has for a long time worked at minimizing transport costs and emissions, and actively participates in research programs that focuses on efficiency. In 2009 the Swedish Forest Industries Federation launched a trail with a vehicle that was 30 meters long and with a Gross Vehicle Weight of 90 tons. Numerous studies have been conducted on this vehicle with regards to safety and reduced emissions. As a result of research and trails, vehicles of Gross Vehicle Weight of 74 tons and a length of 25.25 meters have been implemented in Sweden on specific roads from 2018. With more than a decade of research by highly qualified research institutes in Sweden as well as government funded studies it can be concluded that longer and heavier vehicles are safer and reduces emissions substantially. Also, the vehicles are cost-effective and optimize supply chains. As the EU Green Deal also points out the urgency to reach climate ambitions and lower emissions from transport, it is essential that efficiency and innovation is implemented in all modes of transportation as part of the Sustainable and Smart Mobility Strategy and its action plan. Several member states have already implemented longer and heavier vehicles within national transportation as it is a way of reaching lower emissions and reach higher efficiency in transport. This is a very important work that has been carried out in member states and the EU COM should encourage more of these schemes. The Swedish Forest Industries proposes the following changes in the Directive 96/53/EC: - The European Modular System should be the basis for combinations in the directive, which gives harmonization and flexibility with innovation at the same time. - The current limitations for border crossing should be amended. There should be no limitations on weights and dimensions if the countries of both sides of the borders allow the weight and dimensions. Also width should be set to 2.6 for safety reasons. - There should be no restrictions on number of border crossings if countries passed allow the weights and dimensions. - EU COM should harmonize what the modules are part of European Modular System, with the aim of adding more modules already in use. - Use of larger high-capacity vehicles, should not be tied to alternative fuels or zero emissions as it could lead to a negative effect. Incentive or other directives is more suitable to regulate that. Please read the attached file for more details regarding the suggestions above. Also, there is a summary of evidence in the attached file. Best regards Karolina Boholm Director Transport Policy SFIF – Swedish Forest Industries Federation (Skogsindustrierna) +46702029869 karolina.boholm@forestindustries.se
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Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius)

15 Feb 2022 · Circular economy and Sustainable Product Policy initiative

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

15 Feb 2022 · Circular economy and Sustainable Product Policy initiative

Meeting with Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager)

9 Nov 2021 · Green deal & relevance for the forest industries

Meeting with Taneli Lahti (Cabinet of Commissioner Jutta Urpilainen)

9 Nov 2021 · EU forest agenda

Swedish Forest Industries urges inclusion of forest product substitution benefits in LULUCF targets

8 Nov 2021
Topic — EU regulation on land use and forestry carbon sink targets for 2030.
Message — The organization requests widening the regulation's scope to include substitution effects of forest products replacing fossil materials. They argue targets should be indicative rather than binding, burden sharing should reflect actual potential, and forestry should remain separate from agriculture.123
Why — This would avoid a 15 percent reduction in forest harvests that the current proposal would require.45
Impact — Climate mitigation suffers as fewer fossil products would be replaced by forest-based alternatives.67
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

28 Oct 2021 · SFIF elaborated on the work they are doing to convert the Climate Delegated Act technical screening criteria into practical action on the ground. Their members are keen to be taxonomy compliant. They raised concerns about the draft proposal on the p

Meeting with Pär Holmgren (Member of the European Parliament)

14 Oct 2021 · Fit for 55

Meeting with Asa Webber (Cabinet of Commissioner Ylva Johansson), Brian Synnott (Cabinet of Commissioner Ylva Johansson)

13 Oct 2021 · Forest Strategy

Swedish Forest Industries urges active forest management over carbon storage

7 Oct 2021
Topic — EU initiative on certifying carbon removals and promoting climate-friendly farming and forestry practices.
Message — The organization requests incentives for active forest management that increases growth rather than passive approaches. They emphasize the importance of substitution benefits when wood products replace fossil alternatives. They also call for prioritizing BECCS technology and maintaining the hierarchy that emission reductions come before carbon removals.123
Why — This would maintain wood availability for their products and avoid competitive disadvantages against fossil-based industries.4
Impact — Climate goals lose if passive forestry reduces wood availability and allows other sectors to continue fossil emissions.56
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Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius)

23 Jun 2021 · European Green Deal and the next EU Forest Strategy

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

23 Jun 2021 · European Green Deal and the next EU Forest Strategy

Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen)

15 Jun 2021 · RED2, LULUCF, forests

Meeting with Brian Synnott (Cabinet of Commissioner Ylva Johansson)

27 May 2021 · Forest Strategy, RED II

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Södra Skogsägarna ekonomisk förening

16 Apr 2021 · European Green Deal and the preparation of the EU Forest Strategy

Response to Revision of EU rules on food contact materials

29 Jan 2021

The Swedish Forest Industries Federation (SFIF) represents the Swedish forest industry. Our members refine wood resources to bio-based products. This includes among others pulp, paper, board, packaging material, sawn timber, refined wood products and advanced biofuels. We fully support the need of harmonised food safety regulation and the need to revise the EU rules on food contact materials. The current legislation with Regulation 1935/2004 sets the basic rules for all FCM but leaves room for interpretation such as how to fulfil the general requirement of article 3. This is due to the lack of harmonised measures for non-plastic materials. There is a need for a more consistent and effective implementation of the Framework Regulation 1935/2004. SFIF comments are submitted in the enclosed file.
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Swedish Forest Industries Federation urges holistic EU Forest Strategy

4 Dec 2020
Topic — The European Commission is developing a new strategy to manage EU forests.
Message — The federation requests a stand-alone, holistic strategy covering the entire forest-based value chain. It should focus on stimulating forest growth and acknowledge carbon storage in products.12
Why — This approach secures raw material sourcing and maintains global competitiveness for industries.3
Impact — Environmental advocates lose if the strategy prioritizes industrial wood production over restoration.4
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Response to Protecting biodiversity: nature restoration targets

2 Dec 2020

Swedish Forest Industry Federation, SFIF, welcomes a discussion of nature restoration, but more focus would be on nature conservation management activities. More effective conservation management in protected areas, will enable an effective and sustainable forest management in other areas, for circular bioeconomy purposes. For policy options, we strongly believe in non-binding measures to support restoration activities. Earlier targets on restoration are not met, but the reason is not presented. In our view, voluntary, realistic and concrete targets combined with guidance and financing support, gives incentives to private landowners to carry out activities more than legally binding targets do. The option analysis for legally binding target should therefor investigate the reasons why not a bigger proportion have been restored and learn from Member States with good achievement, before developing legislation. With right incentives, legally binding targets might not be needed. Regarding non-binding and legally binding targets for restoration, the preparatory work and the interaction with stakeholders, such as Member States and forest owners, prior to presenting any proposal will be essential. SFIF sees that the roadmap raises a number of questions: • What areas are to be restored? • What is to be achieved? Is it to focus on improving the forest’s carbon uptake and/or biodiversity? Depending on answer, actions will differ. • Who is to define which areas to target? How to assure that criteria for choosing areas for restoration are science-based? How are the results of the restoration to be judged and by whom? • What happens to a restored area? Can management be carried out, or must a restored area be conserved? Nature is dynamic, so the status of such an area will change. • Who is going to pay for the restoration? • How will Member States and forest type specificities be respected? Forest ecology and dynamics need to be defined on a Member State or regional level. Definitions, measures and result evaluations should also be Member State and/or region specific. Sustainable Forest Management should be the main tool to meet objectives and management should be adaptive and create strong forest owner engagement. It should furthermore define that meeting several objectives simultaneously, such as restoration, climate change mitigation and wood production, is the overarching target. The potential to capture and store carbon dioxide is stated in the roadmap as a decisive objective to restore degraded ecosystems. Promoting increased growth of forests in sustainable forest management is superior to other alternatives to combat climate change. The Impact Assessment should therefor include growth promoting efforts as an important complement to restoration. Forest production and protection can be met simultaneously and are not in contradiction. The aim to ensure the sustainable use of ecosystems, and to improve knowledge and monitoring will thereby be important parts of the roadmap. It is crucial that the restored areas, will be continuously managed. The objective to restore degraded ecosystems with the most potential to capture and store carbon, primary and old-growth forests are pointed out, but definitions of these two concepts is lacking why it therefore would not be appropriate to include the concepts in any objectives. Regarding capture and store of carbon, old trees do not capture carbon as well as young forests. The most effective way to mitigate climate change is to increase growth and to use the biomass for wood-based products as substitute to fossil-based materials and energy. A restoration policy development must be based on understanding the great variety of forests in Europe. A one-size-fits-all solution does not exist; adjustments for local and regional variations is a must and is best done by Member States. Acknowledge Member State lead on work related to conservation and protection of habitats and species.
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Swedish Forest Industries Urge Active Management Over Forest Protection

26 Nov 2020
Topic — Review of EU rules on land use, land use change and forestry.
Message — The federation requests that the EU prioritize active forest management and wood product substitution over increased preservation or set-asides. They propose amending regulations to focus on maintaining forest standing stocks rather than using historical harvesting intensities.12
Why — This would secure raw material availability and prevent new restrictions on harvesting rates.34
Impact — Environmental groups and the agriculture sector may face higher burdens or reduced biodiversity protections.56
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Response to Sustainable Products Initiative

12 Nov 2020

Swedish Forest Industries Federation (SFIF) welcomes the Commission’s action plan on circular economy and the Sustainable Product Initiative acknowledging the importance of ensuring the placement of more sustainable products on the Internal market to support Europe’s transition towards a more circular economy and achieve the goals set under the European Green Deal. SFIF supports the development of products fit for a climate neutral, resource efficient and circular economy, that will also help Europe reduce its waste generation. The markets for recycled materials need to be promoted and it is positive that the European Commission highlights this as a priority area. SFIF needs to point out that overarching sustainability principles can be a good starting point but it will be crucial in the upcoming legislative proposal for a sustainable product policy to have a more sectorial and tailored approaches in order to take into account the needs and characteristics of the different industries.
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Response to Commission Delegated Regulation amending Annex IV to the LULUCF Regulation

14 Sept 2020

The Swedish Forest Industries Federation (SFIF) represents the Swedish forest industry. Our members refine wood resources to bio-based products. This includes among others pulp, paper, board, packaging material, sawn timber, refined wood products and advanced biofuels. Some members have large forest holdings. The Swedish forest industry is highly trade intensive. Almost 90 percent of our members’ pulp and paper production is sold outside of Sweden. The corresponding figure for sawn timber is close to 70 percent. The internal EU market is the biggest receiver of goods. Considering that the method for calculating forest reference levels is extremely complicated, the Commission's and the LULUCFEG work have been carried out in a thorough manner and as objective as possible. We endorse the forest reference level to be applied by Sweden for the period from 2021 to 2025, but we are, however not, happy with the practice used in the expert reviews – a practice that was developed in the voluntary guidelines on how the Regulation should be interpreted. It includes reducing future calculated harvesting levels with regard to how forestry has been conducted historically. This practice was intensively debated during the political negotiations of the LULUCF Regulation, with the result that the wording was deleted. But, the method of calculation was still used when reviewing and revising Member States forest reference levels and accordingly when setting out the delegated Act. SFIF agrees that all sectors should contribute to EU climate objectives, but regarding the LULUCF Regulation, we argue that it does not recognize the full climate mitigation contribution from forests, forestry and forest products. Instead, the Regulation calculation method only sees the forest as a carbon sink. This approach has some severe shortcomings and uncertainties: • It risks leading to policy that limits the contribution of forests, forestry and forest products to climate change mitigation in a situation where all contributions should be maximized. The forest-based sector has a high ability to contribute to decoupling of production and emissions in other sectors by means of substitution, i.e. when forest-based products replace alternative products that have higher carbon footprint. When regarding the forest as a carbon sink, the climate change mitigation potential from material substitution is missed, thereby the European Union is divesting itself from a potentially huge climate neutrality contribution. Furthermore, regarding the forest as only a carbon sink further risks hampering trade and reduces the added value created from forest products in the European Union. This could in turn open for imports from third countries with lower sustainability standards. • It risks created a one-sided perspective that increased standing forest is the preferred forest climate change mitigation strategy. This is however a risky strategy due to potentially negative effects due to natural disasters as well as natural development in older forests. In some Member States’ reports on Forest Reference Levels (FRL), the application of the Regulation’s calculation methods results in very high and most uncertain standing forest volumes. Again, models show one result and reality another. In this context, we wish to point out that the full climate impact of a forest-based sector must be calculated in the following way: Total climate impact = Carbon sink + Fossil reduction – Fossil emissions For the Swedish forest-based sector, the 2017 net positive climate impact amounted to 93 MtCO2e . For the pan-European forest-based sector, the 2018 equivalent number amounted to 806 MtCO2e. This corresponds to c. 20% of all fossil emissions in the European Union .
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Response to Environmental claims based on environmental footprint methods

28 Aug 2020

The Swedish Forest Industries Federation represents the Swedish forest industry. Our members refine wood resources to bio-based products. This includes among others pulp, paper, board, packaging material, sawn timber, refined wood products and advanced biofuels. Some members have large forest holdings. The Swedish forest industry is highly trade intensive. Almost 90 percent of our members’ pulp and paper production is sold outside of Sweden. The corresponding figure for sawn timber is close to 70 percent. The internal EU market is the biggest receiver of goods. We fully support the ambition of the EU to reduce significantly the environmental footprint of products consumed in the Union and to attain the carbon neutrality target by 2050. We also agree with the aim of moving towards a more harmonized approach for providing reliable product environmental information, but we wish to see this done on a voluntary basis (option 2), not by establishing an EU legal framework (option 3). For pulp, paper and board products, our members are already engaged in several different voluntary labels, such as the Nordic Swan, the Blue Angel and EU Ecolabel. This development has been driven by customer demand, i.e. to sell to a specific customer category, market or customer, such labelling is a must. There is, however, no one-size-fits-all, as our members’ customer demands differ. This is because the customers are engaged in diverse markets and sell to a wide variety of end-consumers. Initially, being able to offer a labelled product to a customer might have been a competitive advantage versus other suppliers, but over time, it has developed to be more of a generic feature. It is worth noting that, much time and resources have already been invested by our members acquiring and upholding labelling and now our member wish to benefit on this. Via Cepi, i.e. the European association representing the paper and board industry, we are engaged in the development of a PEFCR for Intermediate Paper Product. This work is not finalized, especially not concerning the land use category, where we are seriously concerned that fresh wood fibers from sustainably managed boreal forests could be seen as an environmental liability. As our members businesses to an over-whelming part is based on products produced from such fresh fibers, applying the present PEFCR for Intermediate Paper Product is not an option. Via CEI-Bois, i.e. European Confederation of wood-working industries, we are engaged to define methods for Environmental Product Declarations. In the area of construction, the first step is to perform LCA analysis of construction products with a harmonized methodology. To this aim, we recommend using the revised EN15804, which was revised to align with the PEF methodology, and to use PEF as a complementary method for other products categories. This would minimize the costs that the industry would incur should it need to adapt to a new methodology for producing Environmental Products Declaration. This factor becomes even more relevant considering that the vast majority of companies in the wood-working sector are small and medium enterprises.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

14 Jul 2020

Swedish Forest Industries welcome the new Circular Economy Action Plan, as we believe it will be beneficial in achieving the overall targets for the European Green Deal. Reduce waste and create better conditions to improve reuse and recycling of goods are necessary to achieve the transition to (more) circularity of resources. The markets for recycled materials need to be promoted and it is positive that the European Commission highlights this as a priority area. However, we would like to emphasize that in the work of promoting the markets, different measures are needed for different materials because the conditions and circularities are different. Targets or requirements for the proportion of recycled raw material can be stimulating for certain materials (e.g. plastic) while for others it could be a major obstacle and can disrupt an already functioning market (e.g. paper/cardboard). The recycling rates for paper and paperboard packaging are already high. Both fresh fibers and recycled fibers co-exist in the same value chain. It’s not a matter of one or the other, instead both of them need each other to be successful. The value chain needs continuously afflux of fresh fibers into the cycle not to be “dehydrated”. The fibers can then be recycled some 7 times and in the end become bioenergy. A demand for mandatory recycled content would mean that producers in North Europe mainly running on fresh fibers would have to import recycled fibers from continental Europe. Costs would go up as well as emissions from transport. Feedstock would be pulled away from those that are 100% recycled based and their business would be hampered. So, intentions can be great, but the end result counteract our functioning circularity, as there is no one-size-fits-all material solution. Reducing (over)packaging is a target that needs to take into account the protection and recognition of the packaging’s functionality. Food loss and products that are discarded due to (under)packaging risk to cause larger environmental impact. In addition, the measures to require mandatory recycled content in packaging might actually lead that more packaging being needed not to compromise with food packaging safety requirements. Reducing the complexity of packaging materials including the number of material and polymers used is a way to simplify the collection and recycling of materials. But, multi-layer packaging solutions, such as plastic laminated board is today an alternative that reduce the need for fossil-based materials. Furthermore, the fibers are recycled already today and there are voluntary initiatives to improve circularity which play an important role for the recycling. The concept of using the best properties of materials to achieve an environmental recyclable packaging should not be jeopardized by the principle of reducing complexity, not when there is a solution for recycling of the multi-layered packaging. Minimum mandatory green public procurement (GPP) criteria and targets for packaging is a powerful method to create a new market for i.e. recycled plastics. For paper and board products, both the fresh and recycled fiber co-exist in the same value chain and should be treated equally. As mentioned above, the fiber cycle needs continuously afflux of fresh fibers into the cycle not to be “dehydrated”. The fibers can then be recycled some 7 times and in the end become bioenergy.
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Response to EU rules on industrial emissions - revision

21 Apr 2020

• We agree to the conclusion that there are significant EU added value and we believe that the Seville process is an important tool in this regard and should continue. A review of the Seville process instead of an opening of the Directive could accommodate most of the issues identified by the IED evaluation eg climate, energy and circular economy. • Many BREFs are neither reviewed nor implemented yet, so we don’t know the Directives full performance. Therefore, changes in the IED is pre-mature. • To publish the inception impact assessment before final version of Ricardo study or SWD, the EC is contradicting its own 'evaluate first' principle set out in its Better Regulation Guidelines. • It is important that the Commission addresses crisis-related matters for industry concerned and increase the timelines for replying. • Legal certainty should be ensured throughout the revision process. No new BREF review cycle should be initiated until a revised IED enters into force. Sectoral issues The evaluation identified possible sectors that might be advantageous to include in the IED. This should be carefully assessed, balancing the increased workload in Seville, the increased administrative burden for smaller installations and the risk of delaying other BREFs with possible environmental benefits of including them in Annex 1 and regulate these sectors EU wide. Implementation issues This is a key issue since we want to achieve equal prerequisites within Europe. In regards of the specific aspects that are to be addressed we especially support Comparability of Member States’ implementation of EU requirements, including BAT conclusions, into permits and verification together with different countries elaboration of BAT conclusions. Industry are ready to support this e.g. by taking part of the IEEG. BREF process We support an overview to improve the BREF process. The process should include a methodology for deriving BAT-AELs and Key Environmental Issues. We believe it is of great importance that BREFs are kept sector specific. A more systematic consideration of cross-media effects on emissions and resource use and the need for a transparent derivation methodology for the setting of BAT-AE(P)Ls should be considered. Access to information We support work to improve access to information, participation in decision-making and access to justice, provided that the information in question complies with CBI and competition rules. Contribution to the CE Via the BREFs, the IED contributes to an enhanced CE via a continued relative decoupling for the use of resources (e.g. water consumption, energy efficiency). The contribution to CE in the Seville process, could be clarified in the guidance for the BREF making process. Interaction with decarbonization of industry With regards to decarbonization efforts, IED Article 9.1 has ensured – and should continue to ensure – a pivotal role to retain the coherence of IED with ETS legislation. Decarbonization could mean an increase in electricity/energy demand and we do not yet know how other emissions will be affected of this transformation. To assume that it is possible to achieve improvement in all other environmental aspects is unrealistic. In order to support the deployment of novel techniques IED Article 15(5) could be used more frequently and for longer periods. Coherence with other legislation The IED has a strong coherence with other environmental policy areas. The overall objective of IED is to address emissions to air, water and land, to prevent the generation of waste and promote efficient use of resources, in order to achieve a high overall level of protection of the environment. Environmental impact from emissions are regulated by other directives such as the Water framework directive and it is important to avoid overlaps. Other We support the aim to have stakeholder meetings and are very interested in participating.
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Swedish Forest Industries Federation urges dual approach targeting agriculture

4 Mar 2020
Topic — EU initiative to prevent products linked to deforestation from entering the market.
Message — The federation wants strict regulations for agricultural imports while exempting legal domestic wood. They promote sustainable management over forest protection to meet global sustainability goals.12
Why — This strategy shields Swedish wood production from regulatory burdens by targeting agricultural commodities.3
Impact — Conservationists lose influence as the proposal favors active forest management over strict protection.4
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Meeting with Brian Synnott (Cabinet of Commissioner Ylva Johansson)

4 Mar 2020 · EU Biodiversity Strategy

Swedish Forest Industries Federation Urges Balanced Climate Law Approach

6 Feb 2020
Topic — This consultation seeks feedback on enshrining the EU's 2050 climate neutrality goal into law.
Message — The federation requests a balanced approach between carbon sequestration, storage, and material substitution. They strongly advise against including fixed targets for forest carbon sinks. The law should ensure global competitiveness and long-term predictability for industrial investments.123
Why — This would protect industrial growth while ensuring wood products replace fossil-intensive materials.45
Impact — Environmental groups lose if the law lacks binding targets for forest carbon sequestration.6
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Response to EU 2030 Biodiversity Strategy

20 Jan 2020

Input from the Swedish Forest Industries are found in the attached file.
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Response to A new Circular Economy Action Plan

20 Jan 2020

The Swedish Forest Industries Federation have concluded some policy recommendations as input and contribution to increase the circularity of the EU’s economy. Enclosed document: Swedish Forest Industries_input_ roadmap CE Action Plan
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Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström)

3 Apr 2019 · Criteria for ILUC / Sustainable forest management / Mrs Åsenius' keynote speech at their event of 10/04/19.

Swedish Forest Industries urge focus on sustainable management

10 Jan 2019
Topic — EU initiative to combat global deforestation and promote sustainable supply chains.
Message — SFIF advocates for increased forest management instead of focus on reserves and formal protection. They suggest meeting land competition by supporting stakeholder cooperation to reach consensus on use. The initiative should promote wood products’ role in the circular bioeconomy.12
Why — Prioritizing management over protection ensures industry access to wood for production.3
Impact — Conservationists lose if the EU favors production over creating strict forest reserves.4
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Meeting with Peter Wehrheim (Cabinet of Commissioner Phil Hogan)

11 Dec 2018 · Commission strategy for a low carbon 2050

Response to Amendment of the import and internal movement requirements of harmful organisms of plants

27 Nov 2018

Swedish Forest Industries Federation representing the Swedish Wood Packaging industry suggest to withdraw alternative a in point 2.3 due to difficulties with the practical implementation and control. Especially when wood packaging is be reused in different geographical areas. Regarding alternative (b) in point 2.3, the ISPM15 standard for wood in packaging is broadly adopted within the European Union and a legaslative implementation of ISPM 15 in the plant health direactive would safeguard plant health whatever harmful organisms occuring. Marking according to ISPM15 also makes it possible to track and trace the origin of the wood material if any problem would occur. Demanding ISPM 15 would likely make the use and reuse of would packaging within EU easier. .
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Response to EU implementation of the Aarhus Convention in the area of access to justice in environmental matters

5 Jun 2018

Föreningen Sveriges Skogsindustrier är en branschorganisation vars medlemmar utgörs av svenska pappers- och masaföretag och sågverk. Medlemmarna bedriver skogsindustriell verksamhet och skogsbruk på egen mark eller på uppdrag av andra skogsägare. Skogsindustrierna anser att de allmänna principerna i Århuskonventionen är viktiga men den mycket breda tolkning av konventionen som drivs av genomförandekommittén är inte i linje med konventionens ursprungliga intentioner. Syftet med konventionen är att ge allmänheten tillgång till information samt tillgång till administrativa och juridiska beslutsprocesser med stor påverkan på miljön och som påverkar många människor. I bilaga I till artikel 9 anges exempelvis kärnkraftverk och gruvindustri. Politik eller juridik? I EU -kommissionens Roadmap anges i fyra punkter förslag till en utvidgning av talerätten enligt den tolkning som konventionens genomförandekommitté gör. En sådan utvidgning riskerar att driva på en utveckling som skapar socioekonomiska kostnader och kan skapa negativa konsekvenser för individer, företag och samhället i stort. Effekten av att från EU centralt diktera vad som ska omfattas av talerätten är en utveckling där politisk styrning allt mer ersätts med juridisk prövning utan krav på den som utnyttjar talerätten att stå för de kostnader som därvid uppstår för samhället eller det enskilda företaget. Det är den nationella lagstiftningen som avses med Århuskonventionen Skogsindustrierna anför att EU:s reglering på miljöområdet främst skett genom olika direktiv, som medlemsstaterna sedan haft att genomföra i nationell lagstiftning. Därmed är det i den nationella lagstiftningen som allmänheten primärt har en enligt konventionen given rätt att agera emot enskilda beslut som fattas. Vilka krav som därvid gäller för att överklaga styrs av nationella lagstiftning och i artikel 9.3 fastslås att den lagstiftning som kan överklagas är den nationella miljölagstiftningen. Här bör EU ta fasta på att det ska röra sig om nationell miljölagstiftning och inte utöka det till att även innefatta talerätt till EU-domstolen. EU är part till konventionen, men kan inte enligt dess lydelse anses omfattas av regler som är riktade mot nationell lagstiftning. EU-domstolen tolkar unionsrätten på begäran av de nationella domstolarna genom att meddela förhands-avgöranden, men har däremot inte möjlighet att överpröva eller upphäva nationella domar; EU-domstolen är inte en appellationsdomstol för de nationella domstolarna och ska heller inte vara det för allmänheten. Utöka inte talerättens omfattning Skogsindustrierna anser inte att det är givet att miljölagstiftning ska ges den extensiva tolkning som kommittén föreslår. Det är förvisso rimligt att man inte enbart ser till vilken benämning som lagstiftningen fått utan även till sitt innehåll, men det innebär inte att all lagstiftning som på något sätt kan beröra vår omgivning ska anses vara miljölagstiftning. Det bör vara en ganska restriktiv tolkning, utifrån vad som normalt anses vara miljöfrågor. Att utvidga omfattningen via EU-lagstiftning skulle inverka på medlemsländernas subsidiaritet i frågan om vilken lagstiftning och vilka beslut som ska omfattas av konventionen. Skogsindustrierna anser också att tillämpningen ska utvidgas mot att även icke bindande regler eller sådana som inte har någon extern effekt ska omfattas. Icke-beslut och beslut utan rättskraft bör inte vara överklagbara. Det skulle t.ex. leda till att beslut måste fattas i varje enskilt fall enkom för att man ska veta när överklagandetiden går ut och det är inte rimligt att ha en sådan byråkrati. Skogsindustrierna varnar också för att utöka den krets som har talerätt till att omfatta allmänheten generellt. Det öppnar exempelvis möjligheter för konkurrenter att via talerätten hindra andra företags utveckling.
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Response to Towards an EU Product Policy Framework contributing to the Circular Economy

4 Jun 2018

Product Environmental Footprint (PEF) The pulp and paper sector has been deeply involved in the development of category rules for Intermediate Paper Products. The methodology is very time and resource consuming. Furthermore, some parts of the methodology as defined in the guide, have shown not to be robust, mature and scientifically grounded. It is valid for the eco/human toxicity and land use impact categories. The Swedish Forest Industries will strongly recommend to simplifying the whole method, at least to exclude land use together with the toxicity categories in order to get the PEF project trustworthy, credible and usable in product policies. Bio-economy strategy/European strategy for plastics in a circular economy A bio-economy, based on renewable and sustainable forest resources, is an integral and essential part of a circular economy in Europe. Wood raw material, the production processes and the products are all parts of circular systems, which contribute to fulfill a resource-efficient and circular economy in Europe. The use of bio-based products must be encouraged and market conditions for uptake of bio-based products improved. Bio-based products can replace many fossil products in the society. Incentives and support to producers are necessary as well as information in public procurement and to consumers, in ecolabels, waste and packaging legislation. Innovation and development of new processes, materials and products are costly and enabling measures are essential. Legislation hampering the use of bio-based products must be reviewed. The forest industry uses wood raw material where it generates the highest value. By using the wood fibers and other components of the raw material as many times as possible, before using it for bioenergy production, the value creation is maximized. The Swedish Forest Industry Federation opposes legislation or other forms of regulation of a cascading principle, which prescribes a certain order of priority for the use of wood raw material. Regulations cannot be expected to keep up with the technological or market developments. It is not always obvious if something is the main product, a by-product or residues, especially in a biorefinery where all parts of the tree is used. Recycled and virgin material in a circular economy Forest-based industry competitiveness is built on a sustainable combination of virgin and recycled fiber material. Recycling prolongs the use of virgin fibers from sustainably managed forests. Fibers have different properties and must be used in a clever and efficient way, choosing the right fiber to the right products. The fiber types complement each other and are part of the total fiber flow in Europe. The Nordic countries with large forest areas are the main suppliers of virgin fibers while the paper industry in continental and south Europe mainly is based on recycled fibers. This continuous flow of fibers from the Nordic countries is vital for the European paper industry as recycled fibers are worn out after some cycles. There will be no recycled fibers without virgin fibers. This means that there must not be requirements on content of recycled material in paper products in any regulations or voluntary instruments. Interface between chemical, product and waste legislation The Swedish Forest Industries welcomes a responsible and clear legislation in order to increase knowledge, to get better information along the supply chain and to substitute chemicals as far as it is possible. However, a resource-efficient circular economy will not be possible by phasing out chemicals, products and waste based on solely inherent properties. A circular economy must be built on a risk assessment – with such an approach, waste can be used as a resource and products and chemicals can be produced according to needs in the society. This approach is especially obvious regarding materials in contact with food. The chemicals issue is global, a worldwide REACH is needed.
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Response to Update of the 2012 Bioeconomy Strategy

20 Mar 2018

The Swedish Forest Industries Federations represents sawmill- and pulp & papermill companies in Sweden. Our vision is to drive growth in the worlds bioeconomy. We welcome the update of the Bioeconomy Strategy since it will be an opportunity to align the strategy with the recent years policy development in EU as well internationally (Paris Agreement, SDGs). The roadmap describes in a very stringent way what a strategy should accomplish and indicate 8 relevant areas of action. From SFIFs point of view we would like to high-light the following: The potentials for bioeconomy development differs substantially between member states. In countries such as Sweden and Finland, the forest-based part forms more than half of the bioeconomy. In other countries, the agricultural sector dominates. A European strategy should take these differences in to account while at the same time promoting and reinforcing common issues and possibilities. • A bioeconomy strategy will lead to the substitution of non-renewable resources with renewables. Forest industry products replace fossil-based and GHG-intensive alternatives for example, in constructions, packaging, chemical industry. In addition, by-products are used as a raw material source for heat, fuel and electricity production. • A bioeconomy strategy will increase resource efficiency. There are opportunities to increasingly use forest industry by-products to produce high-quality carbon-based products. Even if the forest fibre and solid wood will be used more efficiently, additional wood supply will be needed to increase the growth of the bio-economy. • A bioeconomy strategy should strengthen EUs position as global leader in climate policy and sustainable development. • A bioeconomic strategy should cover both short and long-term measures. Different bio-based solutions have different time to market, require varying investments, research and innovation efforts and provide different effects when it comes to replacing fossil and GHG-intensive materials and processes, or other non-renewable resources. This leads to add some points to the 8 very relevant areas that the initiative aims to achieve: Prioritize low-hanging fruits. Industrial wood construction is developing fast. It offers great opportunities to build environmentally friendly and densify existing cities with small disturbances and emissions during construction. In comparison with other bio-based innovations, it has short time to market, requires relatively small investments in research and innovation. I give in relation to costs a very strong contribution to climate change mitigation since the construction sector today is one of the largest sources for GHG-emissions. An increased use of timber in the construction sector gives the strongest substitution effect. Timber also gives forest owners the largest financial contribution from their forests. Increased industrial wood construction therefore also contributes to economic development in rural areas. Competitiveness of existing bio-based industries is key in the transformation. When it comes to support and creation of o markets for bio-based and circular products it is important to point out that the competitiveness of existing industries is key. It is in partnership with these industries new products and services will come. At the same time, the profitability of the sector is heavily dependent on transport costs due to large distances and bulky products. However, appropriate measures to support a growing bioeconomy does not necessarily mean higher operating costs overall. Steering towards a bioeconomy requires that the relative price of fossil materials/non- renewables increases relative to bio-materials or biofuels. This can be achieved either by charging fossil materials/non-renewables with taxes or by subsidising the alternatives. The redistribution effect will be the same, while the financial effects differ in the two options.
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Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström) and Energiföretagen / Swedenergy

26 May 2016 · New sustainability criteria for biomass

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen) and Weber Shandwick and Stora Enso AB

12 May 2016 · Energy Union

Meeting with Miguel Arias Cañete (Commissioner) and Confederation of Swedish Enterprise and

7 Mar 2016 · Round table : European Energy Transition from a Swedish perspective